Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
100% EOU - Classification of goods - Bill of Entry describes the goods as ‘Indonesia robusta coffee beans’ - On examination found to be Coffee husk/bits - Denial from benefit of Notification No.52/2003-Customs - The CESTAT held that, this Tribunal has already remanded the matter for further examination and verification with regard to the procurement certificate, we also remand the case with the following observations: (i) To examine whether the amended letter of the Development Commissioner allows coffee husk/bits as the raw material for the manufacture of instant coffee. (ii) To obtain a letter from the Coffee Board whether Coffee Husk can be used as a raw material for the manufacture of instant coffee that the appellant intends to export.
100% EOU - Classification of goods - Bill of Entry describes the goods as ‘Indonesia robusta coffee beans’ - On examination found to be Coffee husk/bits - Denial from benefit of Notification No.52/2003-Customs - The CESTAT held that, this Tribunal has already remanded the matter for further examination and verification with regard to the procurement certificate, we also remand the case with the following observations: (i) To examine whether the amended letter of the Development Commissioner allows coffee husk/bits as the raw material for the manufacture of instant coffee. (ii) To obtain a letter from the Coffee Board whether Coffee Husk can be used as a raw material for the manufacture of instant coffee that the appellant intends to export.
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